Information Security Policy

APTO Corporation (hereinafter referred to as “the Company”) deeply recognizes that appropriate information management is an important management issue, and in order for customers to use our services with peace of mind, we establish this “Information Security Policy” as a basic policy for information security and declare it. We will also strictly observe the “Information Security Policy” and the separately posted “Privacy Policy”.

The information assets covered by the Information Security Policy include all information held by the Company for business purposes, in addition to information acquired and grasped through the Company’s business activities.

1. Establishment of Information Security Management System

We will strive to protect all information assets held by the Company and comply with laws and other norms regarding information security to build an information security management system so that we can always gain the trust of society. In addition, considering the characteristics of information assets that form the basis of AI development provided by the Company, we will promote operations considering security from the service development stage.

2. Development of Internal Regulations

We will define clear policies and rules regarding information security and promote the protection and appropriate management of information assets through the enactment and dissemination of internal regulations.

3. Scope of Application

We will ensure that all employees of the Company comply with the Information Security Policy and Privacy Policy.

4. Development and Enhancement of Audit System

To confirm whether laws and other norms regarding information security, internal regulations, rules, etc., are appropriately observed and effectively operated, we will conduct information security audits regularly or as necessary. If deficiencies or violations are found as a result of the audit, we will promptly take corrective measures to maintain and improve the management level of information assets.

5. Implementation of Information Security Measures

To prevent risks such as unauthorized access, destruction, information leakage, and alteration of information assets, we will implement appropriate security measures from the aspects of organizational, physical, technical, and personnel security management measures. We will also conduct necessary reviews and improvements in response to changes in technology and society to maintain optimal management systems at all times.

6. Implementation of Information Security Education

We will conduct continuous education and training for all employees to enhance their understanding and awareness of information security and ensure thorough knowledge and behavior for properly handling our information assets.

7. Implementation of Appropriate Contractor Management

When outsourcing all or part of our business, we will thoroughly review the suitability of the contractor and stipulate in contracts, etc., that they maintain a security level equivalent to ours. In addition, to continue confirming that these security levels are appropriately maintained, we will conduct periodic audits of contractors and review management systems.

8. Implementation of Continuous Improvement

We will regularly evaluate and review these initiatives and strive for continuous improvement of information security management based on the results.

Revised: June 27, 2025
APTO Corporation
Ryo Takashina, CEO